Partnerships
PARTNERSHIPS usually designate one of the partners as the point of contact with the IRS in any tax audits.
That partner is called the “tax matters partner.” Only general partners — not limited partners — can act as tax matters partners since the IRS wants someone who can bind the partnership.
The IRS said in August that a partnership whose sole general partner is a “disregarded” limited liability company could only name the disregarded LLC as its tax matters partner, notwithstanding that the LLC
is not considered to exist for tax purposes. The ruling is a breach in the rule that disregarded entities are treated as if they do not exist. It is Revenue Ruling 2004-88.